Justia Government & Administrative Law Opinion Summaries

The Environmental Protection Agency (EPA) approved California regulations under the Clean Air Act that require automakers to produce more electric vehicles and fewer gasoline-powered vehicles to reduce emissions. Several fuel producers, including those of gasoline and ethanol, sued the EPA, arguing that the EPA lacked the authority to approve these regulations as they target global climate change rather than local air quality issues. The fuel producers claimed that the regulations would significantly reduce the demand for liquid fuels, causing them monetary injury.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and held that the fuel producers lacked Article III standing. The court found that the fuel producers failed to demonstrate that automakers would likely respond to the invalidation of the regulations by producing fewer electric vehicles and more gasoline-powered vehicles, thus failing to establish redressability.The Supreme Court of the United States reviewed the case and held that the fuel producers have Article III standing to challenge the EPA’s approval of the California regulations. The Court found that the fuel producers demonstrated injury in fact, causation, and redressability. The Court reasoned that the regulations likely cause monetary injury to the fuel producers by reducing the demand for gasoline and other liquid fuels. The Court also found that invalidating the regulations would likely redress the injury by increasing the sales of gasoline-powered vehicles and, consequently, the demand for liquid fuels. The judgment of the Court of Appeals was reversed and the case was remanded for further proceedings. View "Diamond Alternative Energy, LLC v. Environmental Protection Agency" on Justia Law

The Family Smoking Prevention and Tobacco Control Act (TCA) mandates that manufacturers must obtain approval from the Food and Drug Administration (FDA) before marketing any new tobacco product. In 2016, the FDA classified e-cigarettes as new tobacco products under the TCA. R. J. Reynolds Vapor Co. (RJR Vapor) applied for FDA approval to market its Vuse Alto e-cigarettes, but the FDA denied the application, stating that RJR Vapor failed to prove that marketing the products would protect public health. RJR Vapor, along with a Texas-based retailer and a Mississippi-based trade association, challenged the FDA's denial in the Fifth Circuit.The FDA requested the Fifth Circuit to dismiss or transfer the petition, arguing that only the applicant (RJR Vapor) was "adversely affected" by the denial and thus eligible to seek judicial review. The Fifth Circuit, however, ruled that the venue was proper and denied the FDA's motion.The Supreme Court of the United States reviewed the case and held that retailers who would sell a new tobacco product if not for the FDA’s denial order are "adversely affected" and may seek judicial review under the TCA. The Court interpreted "adversely affected" broadly, consistent with its use in other statutes, and concluded that the retailers' interests were within the zone of interests protected by the TCA. The Court affirmed the Fifth Circuit's decision and remanded the case for further proceedings. View "Food and Drug Administration v. R.J. Reynolds Vapor Co." on Justia Law

A public benefit corporation, Lawyers for Fair Reciprocal Admissions (LFRA), challenged local rules of federal district courts in the Ninth Circuit. These rules require attorneys seeking general admission to be members in good standing of the bar of the state where the district court is located. LFRA argued that these rules prevent its members, who are barred in states outside the Ninth Circuit and do not wish to join another state bar, from seeking general admission to these federal district courts.The United States District Court for the District of Arizona dismissed LFRA’s amended complaint with prejudice. The court found that LFRA had standing to bring claims on behalf of its members, except for the Sixth Amendment claim, which lacked standing. The court dismissed the remaining claims for failure to state a claim, concluding that the Admission Rules did not violate constitutional, statutory, or procedural grounds as alleged by LFRA.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s dismissal with prejudice. The Ninth Circuit held that the Admission Rules are constitutional and do not violate separation of powers, federalism principles, the Privileges and Immunities Clauses, the Equal Protection Clause, the First Amendment, the Full Faith and Credit Act, the Rules Enabling Act, or procedural due process. The court also found that Rules 1 and 83 of the Federal Rules of Civil Procedure do not create a private right of action. The Ninth Circuit concluded that the district court did not abuse its discretion in dismissing the amended complaint without leave to amend, as the complaint could not be saved by amendment. The court also upheld the denial of LFRA’s motion for judgment on the pleadings as procedurally premature. View "Lawyers for Fair Reciprocal Admissions v. United States" on Justia Law

The case involves the Center for Biological Diversity and other petitioners challenging the Environmental Protection Agency's (EPA) Renewable Fuel Standards (RFS) Program for the years 2023, 2024, and 2025. The petitioners include environmental organizations, refiners, a renewable fuel producer, and a biofuel trade association. They argue that the EPA's rule, known as the Set Rule, fails to adequately address the environmental impacts, particularly greenhouse gas emissions and effects on endangered species.The lower court, the United States Court of Appeals for the District of Columbia Circuit, reviewed the EPA's RFS Program standards for 2020-2022 in a previous case, Sinclair Wyo. Refin. Co. LLC v. EPA. In that case, the court upheld the EPA's standards. In the current case, the petitioners argue that the EPA did not adequately explain its reliance on outdated data for greenhouse gas emissions and failed to properly consult with the Fish and Wildlife Service (FWS) regarding the impact on endangered species.The United States Court of Appeals for the District of Columbia Circuit found that the EPA's use of outdated data for greenhouse gas emissions was arbitrary and capricious. The court also found that the FWS's concurrence with the EPA's determination that the Set Rule would have "no effect" on endangered species was not adequately explained. The court remanded the Set Rule to the EPA and FWS for further consideration and explanation without vacating the rule. The court denied the petitions of Neste and the Refiner Petitioners and dismissed SABR's petition for untimeliness and lack of standing. View "Center for Biological Diversity v. Environmental Protection Agency" on Justia Law

T-Mobile sought a refund for statutory service fees paid to the Kentucky Commercial Mobile Radio Service Emergency Telecommunications Board, arguing that the fees did not apply to prepaid cellular customers based on a prior court decision. The Board denied the refund request, leading T-Mobile to file a lawsuit in Franklin Circuit Court. The trial court ruled against T-Mobile, stating that it did not meet the common law refund requirements as outlined in Inland Container Corporation v. Mason County, which necessitates that payments be involuntary or made under misrepresentation.The Court of Appeals affirmed the trial court's decision, agreeing that T-Mobile's payments were voluntary and not subject to refund. T-Mobile then sought discretionary review from the Supreme Court of Kentucky. The Supreme Court granted review, heard oral arguments, and examined the record.The Supreme Court of Kentucky affirmed the Court of Appeals' decision. The court held that T-Mobile was not entitled to a common law refund because the payments were voluntary and not made under misrepresentation. The court emphasized that the payments were not collectible by summary process or fine and imprisonment, and T-Mobile had the opportunity to challenge the fees in court before paying them. Additionally, the court found no evidence of actual misrepresentation by the Board. Therefore, T-Mobile's claim for a common law refund was denied. View "Powertel Memphis, Inc. v. Commercial Mobile Radio Service Emergency Telecommunications Board" on Justia Law

A City of Houston police officer, while responding to an armed robbery, collided with another motorist, Maria Christina Gomez. The officer, Bobby Joe Simmons, was driving in heavy rain with his emergency lights on but did not engage his siren. He did not exceed the speed limit and applied his brakes when the traffic light turned yellow, but his car slid into the intersection and collided with Gomez's vehicle. Gomez sued the City for negligence, seeking damages for her injuries.The trial court granted the City’s plea to the jurisdiction, citing the Texas Tort Claims Act’s emergency exception, which preserves immunity unless the officer acted with "conscious indifference or reckless disregard for the safety of others." The Court of Appeals for the Fourteenth District of Texas reversed this decision, finding a fact question regarding the officer's recklessness. The City then supplemented its plea with additional evidence and appealed again after the trial court denied the plea.The Supreme Court of Texas reviewed the case de novo and concluded that the evidence showed, at most, ordinary negligence rather than recklessness. The court held that Simmons’s actions, including adjusting his radio and not exceeding the speed limit, did not demonstrate a willful or wanton disregard for safety. Consequently, the court reversed the Court of Appeals' judgment and rendered judgment dismissing Gomez’s claim against the City for lack of jurisdiction, reaffirming the City’s immunity under the Texas Tort Claims Act’s emergency exception. View "City of Houston v. Gomez" on Justia Law

Michael Cannata served as a firefighter for the town of Mashpee for over a decade before leaving in 2004 as a "deferred retiree." During his employment, he was enrolled in the town's group health insurance plan, but his enrollment ended upon his departure. In 2021, after turning fifty-five and beginning to collect retirement benefits, Cannata sought to re-enroll in the town's health insurance plan as a retiree. The town denied his request, citing various reasons, including his lack of "time in-service" and the town's practice of denying coverage to retirees not enrolled in the plan at the time of retirement.Cannata filed an action in the Superior Court, seeking a judgment declaring that the town's denial of benefits violated G. L. c. 32B, § 9. The Superior Court judge granted the town's motion to dismiss for failure to state a claim, concluding that Cannata was required to apply for continued coverage and pay the full premium cost during his deferral period in order to later enroll in the town's group health insurance plan upon retirement. Cannata appealed the decision.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that G. L. c. 32B, § 9, neither requires nor prohibits a municipality from enrolling individuals like Cannata in its group health insurance plan upon retirement. The court concluded that the third paragraph of the statute, which the lower court relied on, did not govern Cannata's case. The court determined that municipalities may, but are not obligated to, allow such individuals to enroll in group health insurance upon retirement. The court affirmed the judgment of dismissal on the alternative ground that Cannata's complaint failed to plausibly allege entitlement to relief beyond a speculative level. The case was remanded with instructions to dismiss the complaint without prejudice, allowing Cannata an opportunity to amend his request for declaratory relief. View "Cannata v. Town of Mashpee" on Justia Law

Joanne Pearson, a Republican candidate for Madison County Election Commissioner in District Three, won the election against Walter Young, Jr., a Democratic candidate, by a vote of 5,772 to 3,917. Pearson had filed her application to qualify as a candidate in January 2024, and the Madison County Board of Supervisors approved her candidacy in February 2024. Five citizens, collectively referred to as Brown, appealed the Board’s decision, arguing that Pearson’s application was incomplete and that there was a conflict of interest with the Board’s attorney, Spence Flatgard.The Madison County Circuit Court reviewed the case and denied Brown’s motion to disqualify Flatgard, affirming the Board’s decision to approve Pearson’s candidacy. The court found that Pearson’s application, despite some incomplete areas, met the statutory requirements for the position. Brown then appealed both decisions to the Supreme Court of Mississippi.The Supreme Court of Mississippi reviewed the case and affirmed the lower court’s decisions. The court held that the Board did not act arbitrarily or capriciously in approving Pearson’s candidacy. It found that Pearson’s application substantially complied with the statutory requirements, and any minor irregularities did not mislead the electors. The court also upheld the circuit court’s decision to deny the motion to disqualify Flatgard, finding no conflict of interest as the Board and the election commission were not adverse parties in this matter. The court concluded that the Board’s decision was supported by substantial evidence and was within its discretionary power. View "Brown v. Madison County Board of Supervisors" on Justia Law

The case involves a dispute between several plaintiffs, who are foreign nationals participating in an au pair program, and Cultural Care, Inc., a Massachusetts company that places au pairs with host families in the U.S. The plaintiffs allege that Cultural Care violated their rights under the Fair Labor Standards Act (FLSA) and various state wage and hour laws by failing to pay them legal wages. They also claim violations of state deceptive trade practices laws.The United States District Court for the District of Massachusetts denied Cultural Care's motion to dismiss the complaint, including its defense of derivative sovereign immunity under Yearsley v. W.A. Ross Construction Company. Cultural Care appealed, but the United States Court of Appeals for the First Circuit affirmed the District Court's decision, concluding that Cultural Care had not established entitlement to protection under Yearsley. After the case returned to the District Court, Cultural Care filed a motion to compel arbitration based on agreements in contracts signed by the au pairs with International Care Ltd. (ICL), a Swiss company. The District Court denied this motion, ruling that Cultural Care had waived its right to compel arbitration and that it could not enforce the arbitration agreement as a nonsignatory.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the District Court's denial of the motion to compel arbitration. The court held that Cultural Care, as a nonsignatory to the ICL Contract, could not enforce the arbitration agreement under either third-party beneficiary theory or equitable estoppel. The court emphasized that the arbitration agreement did not demonstrate with "special clarity" that the signatories intended to confer arbitration rights on Cultural Care. Additionally, the plaintiffs' statutory claims did not depend on the ICL Contract, making equitable estoppel inapplicable. View "Posada v. Cultural Care, Inc." on Justia Law

Rhonna Tindall slipped on a layer of ice in a parking lot owned by the County of Nevada and injured her knee. She sued the County, alleging that the icy parking lot was a dangerous condition of public property under Government Code sections 830 and 835. The County moved for summary judgment, claiming immunity under section 831, which provides that a public entity is not liable for injuries caused by weather conditions affecting the use of streets and highways.The trial court granted the County’s motion for summary judgment, ruling that the parking lot was a “street” or “highway” within the meaning of section 831, and that the County was entitled to “weather immunity.” The court also found that a reasonably careful person would have anticipated the potential existence of slippery ice in the parking lot. Tindall appealed, arguing that section 831 immunity does not apply to parking lots, that the dangerous condition resulted from a combination of weather and other factors, and that the County did not meet its burden to show that a reasonably careful person would have anticipated the ice.The California Court of Appeal, Third Appellate District, reviewed the case. The court concluded that the parking lot is a “street” within the meaning of section 831, largely based on the Vehicle Code’s definition of “street” as a publicly maintained place open to the public for vehicular travel. The court found Tindall’s arguments unpersuasive and determined that the County was not liable for her injury caused by the weather condition. The court also held that Tindall’s arguments regarding the combination of weather with other factors and the reasonably careful person standard were forfeited on appeal. The judgment of the trial court was affirmed. View "Tindall v. County of Nevada" on Justia Law